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Mail ProC6SsirA AUDITE ,EP RT hoursperresponse......12.00Sectior FORM X-17A-5

SEC FILENUMBER

OCT30 2017 PART lil

Washington DC FACING PAGEInformatiorggquired of Brokers and Dealers Pursuant to Section 17 of the

Securities Exchange Act of 1934 and Rule 17a-5 Thereunder

REPORT FOR THE PERIOD BEGINNING ()c ()[ % I AND ENDING 9 ) ''(M DD/YY M/DD/YY

A.REGISTRANT IDENTIFICATION

NAME OF BROKER-DEALER: PMR OFFICIAL USE ONLY

ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use P.O.Box No.) FIRM1.D.NO.

(No. and Street)

(City) (State) (Zip Code)

NAME AND TELEPHONE NUMBER OF PERSON TO CONTACT IN REGARD TO THIS REPORT

(Area Code - Telephone Number)

B.ACCOUNTANT IDENTIFICATION

INDEPENDENT PUBLIC ACCOUNTANT whose opinion is contained in this Report*

(Name - ifindividual, state last,first, middle name)

|3>5 i kKahr-uò Pkpr© sorre 4eo AtatwerrA ./-frame som(Address) (City (State) (Zip Code)

CHECK ONE:

Certified Public Accountant

Public Accountant c .2

Accountant not resident in United States or any of its possessions.

FOR OFFICIAL USE ONLY

CJ1

*Claimsfor exemption from the requirement that the annual report be covered by the opinion of an independent public accountant

must be supported by a statement offacts and circumstances relied on as the basis for the exemption. See Section 240.17a-5(e)(2)

Potential persons who are to respond to the collection ofinformation contained in this form are not required to respond

SEC 1410 (06-02) unless the form displays a currently valid OMB control number.

OATH OR AFFIRMATION

I, ()M Vj) † , swear (or affirm) that, to the best of

my knowledge and belief the accompanying financial statement and supporting schedules pertaining to the firm of

of -ÅET S ( , 20 , are true and correct. I further swear (or affirm) that

neither the company nor any partner, proprietor, principal officer or director has any proprietary interest in any account

classified solely as that of a customer, except as follows:

A notary public or otherothcercompletmg.thiscertificateveriflesonlythe identityof theIndMdualmihoolgned-the-documenHowhich thiatertificate-isattached,andnot thetruthfulness,accuracy,or

Stateof Califorala JURAT vanrety reeva rinnumantCountyofSanFrancisco

Subscribedandsw to(oraffirmedbefore Signaturethis 2-7 dayof 20

rovedto onthebasi f satisfacto Titlevidencetobetnepe appearedbefo

N0tafySignature ANTONIOLOCATELLI

Notary Public Commission# 2138154Notary Public- California

This report ** contains (check all applicable boxes): 2 SanFranciscoCounty -0 (a) Facing Page. My Comm.ExpiresJan18,20200 (b) Statement of Financial Condition.0 (c) Statement of Income (Loss).0 (d) Statement of Changes in Financial Condition.0 (e) Statement of Changes in Stockholders' Equity or Partners' or Sole Proprietors' Capital.0 (f) Statement of Changes in Liabilities Subordinated to Claims of Creditors.0 (g) Computation of Net Capital.S (h) Computation for Determination of Reserve Requirements Pursuant to Rule 15c3-3.0 (i) Information Relating to the Possession or Control Requirements Under Rule 15c3-3.

0 (j) A Reconciliation, including appropriate explanation of the Computation of Net Capital Under Rule 15c3-1 and theComputation for Determination of the Reserve Requirements Under Exhibit A of Rule 15c3-3.

0 (k) A Reconciliation between the audited and unaudited Statements of Financial Condition with respect to methods ofconsolidation.

2 (1) An Oath or Affirmation.

9 (m) A copy of the SIPC Supplemental Report.0 (n) A report describing any material inadequacies found to exist or found to have existed since the date of the previous audit.

**For conditions of confidential treatment of certain portions of this filing, see section 240.17a-5(e)(3).

SECURITIESAND EXCHANGECOMMISSION

WASHINGTON, D.C.

ANNUAL AUDIT REPORT

DATE - AUGUST 31, 2017

WHITEHALL-PARKER SECURITIES,INC.

477 Pacific Avenue,Second Floor

San Francisco, CA 94133

CONTENTS

PARTl PAGE

Report of Independent Registered Public Accounting Firm 3

Statement of Financial Condition 4

Statement of Revenue and Expenses 5

Statement of Changes in Stockholder's Equity 6

Statement of Cash Flows 7

Notes to Financial Statements 8-12

SUPPLEMENTAL INFORMATION PURSUANT TO RULE 17a-5

OF THE SECURITIESEXCHANGEACT OF 1934

Computation of net capital requirements pursuant to Rule 15c 3-1 13

Computation for determination of reserve requirements pursuant to Rule 15c 3-3 14

Information relating to the possession or control requirements under Rule 15c 3-3 15

Report by lndependerit Accountant Regarding Exemptions 16-17

Management Exemption Report 18

PART ||

Independent Accountant's Report on Applying Agreed-Upon Procedures

Related to SIPCAssessment Reconciliation 19

NOVOGRADAC& COMPANY are

CERTIFIED PUBLIC ACCOUNTANTS

REPORTOFINDEPENDENTREGlSTEREDPUBLiC ACCOUNTING FIRM

To the Stockholderof Whitehall-Parker Securities Inc.:

We have audited the accompanying statement of financial condition of Whitehall-Parker Securities Inc (aCalifornia corporation) as of August 31 2017; and the related statements of revenue and expenses,changes in stockholder's equitys andcash flows for the year then ended.These financial statements arethe responsibuítyof Whitehall-Parker Securities IncJs management. Our responsibilityls to express anopinion on these financialstatementsbasedon our audit.

We conduatedour audit in accordance with the standards of the Public Company Accounting oversightBoard (United Statesk Those standards require that weplan and perform the audit to obtain reasonableassuranceabout whether the financial statements are free of nísterial misstaternent. Whitehall-Parker

Securities Inc.is not required to haver nor were we engaged to perform,an audit of its internal controlover financial reportings Our audit included consideration of intemal control over financial reporting as abasis for designing audit prodedures that are appropriate in the circumstances, but not for the purpose ofexpressing ari opinion on the effectiveness of Whitehall-Parker Šecurities Inc s internal control overfinancial reporting. Accordingly, we express no such opinion. An audit includes examining, on a testbasis, evidence supporting the amounts and disclosures in the fitiancial statements. An audit also includes

assessing the accounting principles used and significant estimates made by management, as well asevaluating the overall financial statement presentation. We believe that our audit provides a reasonablebasis for our opinion.

In our opinion, the financíal statements referred to above presem fairly, in all material respects, thefinancial position of Whitehall-Parker Securities Inc. as of August 31, 2017, and the results of its

operations and its cash flows for the year then ended in accordance with accounting principles generalyaccepted in the (Jnited States of America.

The supplememal information pursuant to Rule 17a-5 of the Securities and Exchange Act of 1934 hasbeensubjected to audir procedures performed in conjunction with the audit of Whitehall-Parker Securities

lnees financiat statements.The supplemental information is the responsibility of Whitehall4ParkerSecurities lac s inanagement.Our audit roceduresincludgd deterraining whether the suppieinentalinformation retonciles to the financial statements or sheunderlying accountingandather records,asapplicable,andperforming procedures to test the completeness and accuracy of the information presentedin the supplemental information. la forming our opinion on the supplemental information, we evaluated

whether the supplemental information including its forni and content, is presented in conformity withRule 17CF R §240.17a-5.In our opinion, the supplementa0information is fairly stated, in all materialrespects,in relation to the financial statementsas a whole,

Alphart a.Georgia / 6October 25 2017

NOVOGRADAC& COMPANYLLP P 678.867,2333 OFFICE 2325 LakeviewParkway,Suite450F 678.867.2366 Alpharetta,Georgia30009W www.novoco.com

Whitehall-Parker Securities, Inc.STATEMENT OF FINANCIAL CONDITION

August 31, 2017

ASSETS

CURRENT ASSETS

Cash $223,667

Receivables

Commissions $41,139

Other $27,345 $68,484

Total Current Assets $292,151

RESTRICTED DEPOSITS $25,000

OTHER ASSETS

Deposit $3,000

Prepaid $2.253 $5,253

TOTAL ASSETS $322,404

LIABILITIES AND EQUITY

CURRENT LIABILITIES

Accounts Payable $78,437

Federal Income Taxes Payable $6,346

State income Taxes Payable $1,436

Audit & Tax Preparation Fees $6,000Total Current Liabilities $92,219

STOCKHOLDER'S EQUITY

Common Stock(5,000 shares authorized, 800 shares issued $8,000

and outstanding, $10 par value each)

Retained Earnings $222,185

Total Stockholder's Equity $230,185

TOTAL LIABILITIES AND EQUITY $322,404

The accompanying notes are an integral part of the financial statements.

4

Whitehall-Parker Securities, Inc.STATEMENT OF REVENUE AND EXPENSES

ForTheYearEndedAugust31,2017

REVENUE

Commissions $2,378,412

OPERATING EXPENSES

Salaries and Commissions $1,992,053

Office Rent $48,750

Administrative $46,684

Office Expense $11,555

Audit/TaxPreparation $6,000

Telephone $5,746

Other $2,325 $2,113,113

Income From Operations $265,299

INCOME TAXES

Federal Income Tax $78,314

State Income Tax $21,548 $99,862

NET INCOME $165,437

The accompanying notes are an integral part of the financial statements.

5

Whitehall-Parker Securities, Inc.STATEMENT OF CHANGES IN STOCKHOLDER'S EQUITY

ForTheYearEndedAugust31,2017

Common Retained

Sttocis Earnings Total

Balance at September 1, 2016 $8,000 $179,748 $187,748

Dividends Paid ($123,000) ($123,000)

Net Income for the Year *>165,437 $165,437

Balance at August 31, 2016 $8,000 $222,185 $230,185

The accompanying notes are an integral part of the financial statements.

6

Whitehall-Parker Securities, Inc.STATEMENTOF CASH FLOWS

For The Year Ended August 31, 2017

Cash Flows from Operating Activities

Cash Received from Customers/Securities Issuers $2,588,884

Cash Paid to Suppliers/Employees (2,365,400)

Income Taxes Paid (92,080)

Net Cash Provided by Operating Activities $131,404

Cash Flows from Other Activities

Deposit (3,380)

Net Cash (Used in) Other Activities (3,380)

Cash Flows from Financing Activities

Dividends Paid (123,000)

Net Cash (Used in) Financing Activities (123,000)

Net increase in Cash $5,024

Cash at September 1, 2016 $218,643

Cash at August 31, 2017 $223,667

Reconciliation of Net Income to Net Cash Provided by Operating Activities

Net income $165,437

Adjustments to Reconcile Net Income to Net Cash Provided by Operating Activities

Depreciation and Amortization 3,315

(Increase) Decrease in:

Accounts Receivable 179,895

Increase (Decrease) in:

Accounts Payable (143,371)

Income Taxes Payable (73,872)

Net Cash Provided by Operating Activities $131,404

The accompanying notes are an integral part of the financial statements.

7

WHITEHALL-PARKER SECURITIES,INC.

NOTES TO FINANCIAL STATEMENTS

FOR THE YEAR ENDED AUGUST 31, 2017

1. ORGANIZATION AND NATURE OF BUSINESS

Whitehall-Parker Securities, Inc.(the "Company") was incorporated on February 1, 1982 under the laws

of the state of California. The Company is a broker/dealer registered with the Securities and Exchange

Commission("SEC"),and is a member of the Financial Industry Regulatory Authority("FINRA") and the

Securities Investor Protection Corporation("SIPC"). The Company provides retail securities brokerage

and portfolio advisory services.

2. SIGNIFICANT ACCOUNTING POLICIES

Use of Estimates:

The preparation of financial statements in conformity with generally accepted accounting principles

requires management to make estimates and assumptions that affect the reported amounts of assets

and liabilities and disclosures of contingent assets and liabilities as of the date of the financial

statements and to make estimates and assumptions that affect the reported amounts of revenues and

expenses during the reporting period. Actual results could differ from those estimates. Significant

estimates include valuing advisory fees earned which are paid quarterly in arrears.

Revenue Recognition:

The Company performs most of its transactions on behalf of customers through its clearing

firm(Pershing, LLC)on an agencybasis, but some cleared transactions are performed on a riskless

principal basis(e.g.bond purchases and sales). For all transactions through the clearing firm, the

Company is credited commissions at settlement date, but the Company recognizes revenue at trade

date(typically three business days before settlement date). For transactions performed directly with

investment issuers outside of the Company'sclearing firm, the Company recognizes revenue when the

investment issuer confirms to the Company that all application paperwork and funds are received by the

investment issuer in good order and/or at the close of a transaction escrow. For quarterly advisory fees,

the Company recognizes revenue as an estimate of the monthly portion of the quarterly fees projected

to be received based on current underlying client portfolio valuations.

8

2. SIGNIFICANT ACCOUNTING POLICIES(CONTINUED)

Income Taxes:

Deferred income taxes are provided on an asset and liability method whereby deferred tax assets are

recognized for deductible temporary differences. Deferred tax liabilities are recognized for taxable

temporary differences. Temporary differences are the differences between the reported amounts of

assets and liabilities and tax bases. Deferred tax assets are reduced by a valuation allowance when, in

the opinion of management, it is more likely than not that some portion or all of the deferred tax assets

will not be realized. Deferred tax assets and liabilities are adjusted for the effects of changes in tax laws

and rates on the date of enactment. Management hasdetermined there are no deferred tax assets or

liabilities that are required to be recorded.

The preparation of financial statements in conformity with generally accepted accounting principles

requires the Company to report information regarding its exposure to various tax positions taken by the

Company. The Company has determined whether any tax positions have met the recognition threshold

and has measured the Company's exposure to those tax positions. Management believes that the

Company hasadequately addressed all relevant tax positions and that there are no unrecorded tax

liabilities. Federal and state tax authorities generally have the right to examine and audit the previous

three years of tax returns filed. Any interest or penalties assessed to the Company are recorded in

operating expenses.

Cash Equivalents:

The Company considers all unrestricted investment instruments purchased with original maturities of

three months or less to be cashequivalents. At August 31, 2017 there were no cash equivalents, other

than the required $25,000 deposit invested in a money market account held at the Company's clearing

firm(Pershing, LLC).

Depreciation/Amortization:

The Company provides for depreciation in amounts sufficient to relate the cost of depreciable assets to

operations over their estimated service lives, principally using the Modified Accelerated Cost Recovery

method(MACRS). During the fiscal year ending in 2017, the Company had no depreciable assets with a

book value greater than zero during the year. The Company amortizes prepaid assets in equal monthly

amounts over the term of the prepaid item. Currently the Company is amortizing one prepaid

subscription for a due diligence system(Al losight) offered by an outside vendor.

Accounts Receivable:

Management of the Company considers all accounts receivable to be collectible at August 31, 2017.

Therefore, no allowance for doubtful accounts is required.

9

2. SIGNIFICANT ACCOUNTING POLICIES(CONTINUED)

Accrued Expenses:

The Company accruesfor commissions payable to all registered representatives of the firm all amounts

earned in a month but not payable until the 15th of the following month, per the terms of the

underlying independent contractor agreements between the Company and its registered

representatives. An estimate is made for all other trade payables, which are typically small and similar

from month to month, which is included in accounts payable on the accompanying statement offinancial condition.

Fair Value Measurements:

The Company reports balances that are required or permitted to be measured at fair market value in

accordance with existing accounting pronouncements. Fair value is a market-based measurement, not

an entity-specific measurement. Therefore, a fair value measurement should be determined based

upon the assumptions that market participants would use in pricing the asset or liability. As a basis for

considering market participant assumptions in fair value measurements, a fair value hierarchy is used

that distinguishes between market participant assumptions based on market data obtained from

sources independent of the reporting entity(observable inputs that are classified with Levels l and 2 of

the hierarchy) and the reporting entity's own assumptions about market participant assumptions

(unobservable inputs classified within Level 3 of the hierarchy).

Level 1 inputs utilize quoted prices(unadjusted) in active markets for identical assets or liabilities that

the Company has the ability to access. Level 2 inputs are inputs other than quoted prices in Level 1 that

are observable for the asset or liability, either directly or indirectly. Level 2 inputs may include quoted

prices for similar assets and liabilities in active markets, as well as inputs that are observable for the

asset or liability(other than quoted prices) such as interest rates, foreign exchange rates, and yield

curves that are observable at commonly quoted intervals. Level 3 inputs are unobservable inputs for

the asset or liability which are typically basedon an entity's own assumptions asthere is little, if any,

related market data available.The Company's assessmentof the significance of a particular input to thefair value measurement in its entirety requires judgment and considers factors specific to the asset or

liability.

The carrying values of cash, restricted deposits, receivables, and accounts payable are reasonableestimates of their fair values due to their short-term nature.

10

3. NET CAPITAL

The Company is subject to the Securities and Exchange Commission Uniform Net Capital Rule(SEC Rule

15c3-1), which requires the maintenance of minimum net capital and requires that the ratio of

aggregate indebtedness to net capital, both as defined, shall not exceed 15 to 1. At August 31, 2017 the

Company had net capital of $197,587, which was $191,439 in excess of its required net capital of

$6,148. The Company's net capital ratio(aggregate indebtedness to net capital) at August 31, 2017 was0.47 to 1.

4. SECURITIESOWNED AND FAIR VALUE MEASUREMENTS

The Company owns no securities, other than a required $25,000 money market account on deposit with

the Company's clearing firm(Pershing, LLC)since 1992. The Company owned no other securities during

the fiscal year. The Company accounts for the money market account held at the clearing firm without

haircuts at a non-fluctuating value of $25,000, which is the value reported in the quarterly statements

provided by the clearing firm since 1992.

5. CONCENTRATIONS OF CREDIT RISK

The Company places its cash in one checking account with Wells Fargo Bank, a high credit quality

financial institution. The Company's account at this institution is insured by the Federal Deposit

Insurance Corporation("FDIC") up to $250,000. To reduce its risk associated with the failure of sucha

financial institution, the Company evaluates periodically the rating of the financial institution in which it

maintains deposits.

6. RELATED PARTIES

The Company did not conduct any operations with any related parties during the year, other than

processing securities transactions requested by the Company's registered representatives for the

benefit of themselves and their family members. These transactions were not material to the

Company's operations individually or in total.

11

7. COMMITMENTS AND CONTINGENCIES

Commitments:

The Company has no commitments other than office rent payable at a rate of $4,250 per month until

May 31, 2018.

Litigation:

The Company occasionally is involved in legal proceedings in the ordinary course of business. Such

matters are subject to many uncertainties, and outcomes are not predictable with assurance. Currently,

the Company is not involved in any legal proceedings and is unaware of any legal claims that may be

made against the Company.

8. SIPC RECONCILIATION REQUIREMENT

SEC Rule 17a-5(e)(4) requires a registered broker/dealer to file a supplemental report which includes

procedures related to the broker/dealer's annual general assessment reconciliation or exclusion from

membership forms.

9. SUBSEQUENT EVENTS

Management has evaluated subsequent events through October 27, 2017, the date on which the

financial statements were available to be issued. There were no subsequent events that require

adjustment or disclosure in the financial statements.

12

Whitehall-Parker Securities, Inc.COMPUTATION OF NET CAPITAL REQUIREMENTS PURSUANT TO RULE 15c 3-1

August 31, 2017

NET CREDITS

Shareholders' Equity $230,185

DEBITS

Non-Allowable Assets $32,598

NET CAPITAL $197,587

Greater of 6 2/3% of Aggregate Indebtedness or $5,000 $6,148

EXCESSNET CAPITAL $191,439

SCHEDULE1-RECONCILIATION OF AUDITED NET CAPITAL TO UNAUDITED NET CAPITAL AT AUGUST 31, 2017

Net Capital Per Unaudited Focus Report IIA $205,369

Adjustments

Federal Income Taxes $6,346

State Income Taxes $1,436

Net Capital Per Audit Report $197,587

The accompanying notes are an integral part of this statement.

13

Whitehall-Parker Securities, Inc.

COMPUTATION FOR DETERMINATION OF

RESERVEREO.UIREMENTSPUSUANT TO RULE15c 3-3

August 31, 2017

The Respondent claims an exemption from Rule 15c 3-3 under Section (k)(2)(ii).

14

Whitehall-Parker Securities, Inc.

INFORMATION RELATINGTO THE POSSESSION

OR CONTROL REQUIREMENTS UNDER RULE15c 3-3

August 31, 2017

The Respondent claims an exemption from Rule 15c 3-3 under Section (k)(2)(ii).

15

WHITEHALL-PARKER SECURITIES,INC.

Exemption Report for the Year

Ended August 31, 2017

Review Report of Independent Auditors

NOVOGRADAC& COMPANY ar.CERTIFIED PUBUC ACCOUNTANTS

REPORT OF INDEPENDENTREGISTEREDPUBLIC ACCOUNTING FIRM

To the Stockholder ofWhitehall-Parker Securities lue,:

We have reviewed management's statements, included in the accompanying Management ExemptionRepoet, in which (1) WhitehalkParker Securities Inc. identified the following provisions of 17 CI.R.§15c3-3(k) under which Whitehall-Parker Securities Inc. claimed an exemption from D CS.R.§2400503-3 pursuant to the provision of paragraph (k)(2)(ii) (the "exemption provisions") and (2)

Whitehall-Parker Securities Inc. stated that Whitehall-Parker Securities Inc, met the identiiled exemptionprovisions throughout the most recent fiscal year without exception. WhitehaihParker Securities ine.'smanagement istesponsible for compliance with the exemption provisions and its statements.

Our review was conducted in accordance with the standards of the Public Company AccountingOversight Board (United States) and, accordingly, included inquiries and other required procedures toobtain evidence about Whitehall-Parker Securities Inc.'s compliance with the exemption provisions. Areview is substantially less in scope than an examination, the objective of which is the expression of anopinion on managemenfs statements. Accordingly, we do not expresssuch an opinion,

Based on our review, we are not aware of any material modifications that should be made to

management's statements referred to above for them to be fairly stated,in all material respects, based onthe provisions set forth in paragraph(k)(2)(ii) of Rule 15c3-3under the Securities Exchange Act of 1934.

Alphar a GeorgiaOctober 25 2017

NOVOGRADAC& COMPANYLLP P 678.867.2333 OFFICE 2325 LakeviewParkway,Suite450F 678.867.2366 Alpharetta,Georgia30009W www.novoco.com

Whitehall-Parker Securities, Inc.

Management Exemption Report

Fiscal Year Ended August 31, 2017

Management of Whitehall-Parker Securities, Inc.("WPS") is responsible for complying with 17 C.F.R.

240.17a-5, "Reports to Be Made by Certain Brokers and Dealers". We have performed an evaluation of

the firm's compliance with the requirements of 17 C.F.R.240.17a-5, and the exemption provisions in 17

C.F.R.240.15c3-3(k) (the "exemption provisions"). Based on this evaluation, we make the following

statements to the best knowledge and belief of WPS:

(1) We identified 17 C.F.R.240.15c3-3(k)(2)(ii) under which WPS claimed an exemption from 17

C.F.R.240.15c3-3.

(2) WPS met the identified exemption provision throughout the most recent fiscal year ended

August 31, 2016 without exception.

Robert Yu Loo

President/CEO

NOVOGRADAC& COMPANY are

CERTIFIED PUBLIC ACCOUNTANTS

RÈPORT OF INDÈPENDENTREGISTERED PUBLIC ACCOUNTING FIRM ONAPPLYiNG AGREEDAUPON PROCEDURES

To the Stockholder of Whitehall-Parker Securities Inc.:

In accordance with Rule 17a-5(e)(4) under the Securities Exchange Act of 1934 and with the SIPC Series 600Rules, we have performed the procedures enumerated below with respect to the accompanying General

Assessment Reconciliation (Form SIPC-7) to the Securities investor Protection Corporation (SIPC) for the yearended August 31; 20i7, which were agreed to by Whitehal-Parker Securities Inc.,the Securities and ExchangeCommissión;Finaricialindustry Regulatory Authority, and $1PC, solely to assist you and the other specifiedparties in evaluating WhitehalkParker Securities Inc 's compliance with the applicable instructions of Form SIPC-

7. WhitehalleParker Securities Inc.asmanagement is responsible for Whitehal-Parker Securities Inc s compliancewith those requirements. This agreed-upon proceduresengagement was conducted in accordance with attestationstandards established by the Public Company Accotnting Oversight Board (United States). The sufficiency ofthese procedures is solely the responsibility of those parties specified in this report Consequendy, we make norepresentation regarding the sufficiency of the procedures described below either for the purpose for which thisreport hasbeertrequested or for any other purpose.The procedureswe performed andour findings are as follows:1) Compared the fisted assessmentpayments in Form SIPCs7 with respective cash disbursement records entries

listed la the detaled list ofchecks ist thetheeleregísteranotingnodifferences;

2) Compared the amounts reported on the audited Form X-17A-5 (Focus Report) for the year endedAug,ust31, 2017 with the amounts reported in Form SÍPC-7 for the year ended August 31, 2017, noting nodifferences;

3) Compared any adjustments reported in Form SIPC-7 with supporting schedulesand working papers,of whichthere were none,aioting no differencest

4) Proyed the arithmetical accuracy ofthe calculations reffected in FormSIPC47and in the related schedules andworking pápers,of which there were none, supporting the adjustments, noting nódifferences; and

5) Comparedthe amount of anyoverpayment applied to the outrent assessmentwith the FormSIPC-7 on whíchit was originally computed; noting no overpayment was applied to the current assessment.

We were not engaged to, and did not conduct an examination,the objective of which would be the expression ofan opinion on complíance. Accordingly, we do not express such an opinion. Had we performed additionalprocedures; other matters might have come to our attention that would have been reported to you.

This reporeis intended solely for the information and useof the specified parties listed above and is not intendedto be andshould not be used by anyone other than these specified parties.

Alphare t GeorgiaOctober 25, 2017

NOVOGRADAC& COMPANYLLP P 678.867.2333 OFFICE 2325 LakeviewParkway,Suite450F 678.867.2366 Alpharetta,Georgia30009W www.novoco.com